Denham respects the privacy of visitors to our website. This policy describes how and when we gather and use information from visitors to our website located at www.denhamcapital.com.

Data We Gather

We generally record certain usage information, such as the number and frequency of visitors to our website. This information may include the websites that you access immediately before and after your visit to our website, the Internet browser you are using and your IP address. If we use this data at all, it will be on an aggregate basis, and we will not disclose to third parties any personally identifiable information in connection with such use.

Our website may employ cookies or other technology to gather information about the usage of our website to help us improve the content, usability and functionality of our website, and to remember certain user attributes. This helps us better tailor our website for users and better understand how many new and repeat users visit our website, which features or pages are most popular, and user browsing and usage patterns. You can set your Internet browser to prompt you before you accept a cookie, accept cookies automatically or reject all cookies. However, if you choose not to accept cookies from our website then you may not be able to access and use all or part of our website or benefit from the information and services which it offers.

Personally Identifiable Information

If you voluntarily submit information to us (for example, in connection with a request for general information), we may record and use personally identifiable information, such as your name, phone number and e-mail address, for reasonable business purposes, including for the purpose of fulfilling your request. We will not use your personally identifiable information for any other purpose without your permission.

We may use internal service providers to operate our website and employ other persons to perform work on our behalf, such as sending postal mail and e-mail. These persons may have access to your personally identifiable information you submit through our website, but only for the purpose of performing their duties. These persons may not use your personally identifiable information for any other purpose.

We will not provide any of your personally identifiable information to any other persons, except if we are required to make disclosures to third parties (including the government) in connection with a lawsuit, subpoena, investigation or similar proceeding. We can, and by visiting our website you authorize us to, disclose any such information in those circumstances.

Linked Sites

This website may contain links to sites owned and operated by other parties. We are not responsible for and have no control over the privacy policies of those sites. We encourage you to review the privacy policies of those sites prior to providing them with any information.

Changes to Policy

If we materially change our privacy policies or practices, we will also update this policy to notify you of such changes.

Questions

If you have any questions regarding our policy or our privacy-related practices, please contact us by e-mail at Tim.Smith@denhamcapital.com or by telephone at 617-531-4864.

Last revised: July 1, 2008